Fluentia Privacy Policy (updated 13.6.2023)

‍Privacy and responsible business practices are important to us. At Fluentia Ltd (later Fluentia), data protection is seen as part of all our business activities.
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‍RECORD KEEPER
Fluentia Oy (business ID: 3179241-8)
Postal address: Tykistökatu 4 B, 20520 Turku
Questions and requests concerning data protection can be sent to: privacy@fluentia.fi.
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‍PURPOSE OF THE REGISTER AND DATA COLLECTED
We collect the personal data described below only for predefined purposes, which are described in more detail in the following sections:
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‍Job applicants
‍In connection with the job search and recruitment process, we process the following data about you:
- First name and surname
- Email

In addition to the information mentioned above, we process the following data to the extent that you provide it to us during the recruitment process:
- Phone number
- Postal address and municipality of residence
- Current employer
- Education and work history
- Skills and professional competences
- LinkedIn, Github and Twitter etc. public profile information and information you share via your CV and any other information you provide

The following information collected during the recruitment process will be stored to the extent appropriate:
- An assessment of your suitability for the position you are applying for
- Written communication with you
- Information provided by any referees you may have
- Information about the progress of the recruitment, the outcome and the implementation of any assignment included in the recruitment
- Any feedback we may have for you, to help you improve your job or job search

The information will be used in the recruitment process and in the processing of your job application for communication during the recruitment and job search phase, and to support any induction and start of employment.

In principle, personal data will only be collected from the individual. With the person's consent, data may also be obtained from other sources, for example from referees nominated by the person.

‍Customers and partners
‍If you are a customer or partner of Fluentia, we may process the following information about you:
- First and last name
- Customer or partner company details including contact details
- Individual's status and contact details (email address and telephone number)
- Other information provided by the individual (customer feedback and event attendance details and newsletter subscriptions)
- IP address information is used to manage the customer and partner relationship and to market, deliver and develop Fluentia's services and events.

Personal data is collected in principle within the framework of the management and implementation of the customer and partnership relationship. Data is also collected from the individual when, for example, you register for an event organised by us, subscribe to our newsletter or visit our website.‍

Other contacts
‍If you contact us, for example to enquire about our services, register for an event we organise or subscribe to our newsletter, we may process the following information about you to the extent that we have received it from you:
- First and last name
- Email
- Phone number
- Name of organisation with contact details
- Country
- Personal status and contact details
- IP address

Other information you provide us with if you wish (for example, the web address of your LinkedIn profile)
The data will be used to process your contact or request and for communication between you and Fluentia. In addition, the data will be used to market, implement and develop Fluentia's services and events.

Personal data is collected from the individual in principle. In addition, data may be collected on the basis of the use of our website by means of cookies. For more information on our cookie policy, please see "Cookie Policy".
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‍‍LEGAL BASIS AND PURPOSE OF THE PROCESSING OF PERSONAL DATA
The legal basis for the processing of personal data under the EU General Data Protection Regulation is primarily the legal interest of Fluentia. In addition to or instead of the above, the processing may also be based on the performance of a contract between Fluentia and you, in which case we process personal data for the purposes and in fulfilment of the obligations specified in that contract. In some cases, our processing may be based on your separate consent instead of or in addition to the above. The data collected will not be used for automated decision-making or profiling.

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HOW LONG WE PROCESS PERSONAL DATA
We process personal data only for as long as we have a legal right or obligation to process the personal data. We regularly assess the necessity of the data we store and delete data that is no longer necessary.
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‍COOKIE POLICY
Fluentia uses cookies on its website to facilitate your use of the site. Cookies alone do not allow the user to be identified. Cookies and the information they collect are also used to analyse the usability and use of the website, to monitor usage and to improve the website.

Our website uses the following cookies:
- Google Analytics. - Google Analytics - We use Google Analytics to monitor the use of the website.

You can prevent the use of cookies on your computer by changing your browser settings, which may prevent all parts of the pages from being displayed on your computer.
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‍REGULATORY TRANSFER OF DATA AND TRANSFER OF DATA OUTSIDE THE EU OR EEA
Data will not be disclosed to other parties by regulation. Data may be published to the extent agreed with the customer.

Data may also be transferred outside the EU or EEA by the controller. In such cases, we will ensure, by contract and/or as required by law, that the disclosure or transfer is carried out in accordance with the applicable data protection legislation, so as to ensure an adequate level of protection for the personal data disclosed or transferred.
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‍PRINCIPLE OF REGISTER PROTECTION
The processing of the register is carried out with due care and the data processed by the information systems are adequately protected. Where the data are stored on Internet servers, the physical and digital security of the hardware is adequately ensured. The controller shall ensure that stored data, as well as access rights to servers and other information critical to the security of personal data, are treated confidentially and only by employees whose job description includes this.

The detailed security principles are set out in Fluentia's Security Policy, which follows the ISO27002 (2013) structure where applicable.
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‍RIGHT TO VERIFY AND REQUEST CORRECTION
Every person in the register has the right to verify the data recorded in the register and to request the correction of any inaccurate information or the completion of incomplete information. If a person wishes to check or request the rectification of data recorded about him or her, the request must be sent in writing to the controller. The controller may, if necessary, ask the applicant to prove his or her identity. The controller will respond to the customer within the time limit set by the EU Data Protection Regulation (usually within one month).
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‍OTHER RIGHTS RELATING TO THE PROCESSING OF PERSONAL DATA
A data subject has the right to request the erasure of personal data concerning him or her from the register ("right to be forgotten"). Data subjects also have other rights under the EU General Data Protection Regulation, such as the restriction of the processing of personal data in certain circumstances. Requests should be sent in writing to the controller. The controller may, if necessary, ask the applicant to prove his or her identity. The controller will respond to the customer within the time limits set by the EU GDPR (as a general rule, within one month).

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